Privacy Policy

DigitalFlare understands the importance of your personal privacy. Therefore, we have created this Privacy Policy so that you know how we use and disclose your information when you make it available to us.

SourceFlare Ltd. ("DigitalFlare" "we" "us" or "our") provides technologies and data tools for online marketers, web and mobile applications. In the course of providing our website and our services (our "Services") we collect information about you and about your users ("End Users"). This privacy policy explains how we collect, use, share and protect information about you as well as how we use information we collect about the End Users. It also explains what your choices are regarding the collection, use and sharing of your information and that of your End Users. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY YOU MAY NOT ACCESS OR OTHERWISE USE OUR SERVICE OR PARTICIPATE IN OUR SERVICES.

Key aspects of our privacy practices described in this Privacy Policy include the following explanations:

• The information we collect and why we collect it;
• How we use that information;
• How we share information; and
• The choices we offer.

Personal information is information that we hold about you, and which identifies, or together with other information may identify, you and/or your End Users.

We set out below examples of the different ways in which we use personal information and where this personal information comes from.

2.1 Information about you, as a user of our services or Website:

2.1.1 Information you provide to us:

Registration Information:
When you sign up for the Services, we ask you for information such as your username, password, email address, website, Skype ID, phone number, job role and country of residence. This information is necessary for us to provide you the Services. If you do not provide this information we would not be able to provide the Services to you.

Social Media Log-In:
If you choose to connect to the Services using credentials from a third party service like Google will need to collect authentication information and encrypted access credentials. For Google we ask for information such as your Google account email address, and access to your public profile data including your user name and profile photo.

We use this information to identify you in your use of the Platform. For example, we may take your Third Party Service profile photo and present it alongside your Third Party Service email address.

Feedback:
Any feedback, questions, comments, suggestions, ideas, or the like that you send to us. These will be treated as non-confidential and non-proprietary and we may use them and share them with third parties. This is described more fully in Terms and Conditions.

2.1.2 Information we collect passively from you - Usage, Log, Cookies:

When you use our Services, we use cookies and similar technologies to collect information about your location, your application, your activities in the DigitalFlare platform, information about your device and log information. This is described in more detail in the Section "Cookies and Other Technologies" below.

The information includes:

Location Information:
Information about your estimated location which may be deduced by various technologies including: IP address.

Device Information:
Information about the device you are using such as, hardware model, operating system, application version number and browser, mobile network information, IP addresses, user names, real names, email addresses and other custom properties.

Activity Data:
This includes information, such as the time of an event, how you came to the Services, what search engine and search keywords you may have used to get to the Service, pages you visit on the Service, your activity on the forum. Your actions with respect to emails we send you such as when you open them and what you click in them.

Log Information:
Server logs regarding how you use the Services or view content provided by Google, which may include: Google search queries, telephony log information like phone number, calling party number, forward number, time and date of calls, duration of calls SMS routing information and types of calls, IP address, device event information such as crashes, system activity, hardware settings, browser type, browser language, the date and time of your request and referral URL, cookies that may uniquely identify your browser or your Google Account.

2.1.3 Google Analytics:

We use a tool called "Google Analytics" to collect some information we listed above about your use of the Services. We use the information we get from Google Analytics to improve the Services and to help you improve your Application. In order to collect this information, Google Analytics may set cookies on your browser or mobile device, or read cookies that are already there. Google Analytics may also receive information about you from apps you have downloaded, that partner with Google. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google's ability to use and share information collected by Google Analytics about your visits to the Services to another application which partners with Google, is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. Please review those and see http://www.google.com/policies/privacy/partners/ for information about how Google uses the information provided to Google Analytics and how you can control the information provided to Google. To prevent your data from being used by Google Analytics, you can download the Google Analytics opt-out browser add-on for Google Analytics which can be found here: https://tools.google.com/dlpage/gaoptout/.

2.1.4 Information we collect from third parties

We use Linkedin Sales Navigator to locate and connect with individuals that may find our services interesting. You may decline such requests or remove the connection at any time. You can control which messages you receive by adjusting your communication preferences on the Privacy Settings page or using the unsubscribe options in the footer of messages as applicable (e.g., Sales Navigator InMails).

2.2 Information about your End Users:

By using our technologies to optimize your advertising revenues or any other purpose, we collet information about our End Users in order to make a decision when needed; We use technologies such as Software Development Kits (SDKs) or Advanced Programming Interfaces (APIs) to collect information about your End Users' technical data, mobile devices, uses of your website or application and interaction with advertising as described below.

We use these technologies to recognize the End User's device and to track the End User's activities in the your application in order to provide our Services to you and in accordance with your instructions.

These technologies are hooked into your website, web or mobile applications in accordance to a technical integration instruction.

It is your responsibility to disclose clearly, and obtain consent to, our use of cookies on your End User's devices, how we collect and use your End User's data as well as our sharing it with third parties and processing information on servers outside of the European Economic Area.

We collect and store the following End User information:

Technical data:
This includes information, such as URL information, cookie data, IP address, network connection type (e.g., WiFi, 3G, LTE), mobile network carrier in case applicable, browser type, language, operating system, identifiers for advertising Google Advertising ID or IDFA and geographic or geolocation information and DigitalFlare application version.

Usage Statistics:
Statistical information about the End User. this includes, amount of times users was noticed by our app during a given day, etc.

Ad Interaction:
We collect data about how End Users interact with ads served by our services. This includes viewing, clicking on the ads as well as whether or not an End User performed post-click action like buying, subscribing or installing any of the advertised content.

Country of Residence Information:
Information about the country in which the End User might reside as deduced by various technologies including: IP address.

Where available, we combine an End User's device id or advertising with non personally identifiable information in order to allow us to uniquely identify such End User's device for purposes of storing specific and aggregate usage preferences and data.

We use personal information to provide our Services to you, to improve our Services and to protect our legal rights. We limit the collection of personal information to that which is relevant for these purposes. We will not store, access, transmit, retain or otherwise use personal information in any way that is incompatible with the purposes for which it has been collected or stored as described in this Privacy Policy, unless such alternative use is authorized in writing.

To the extent EU data protection law applies to our processing of personal data about you as user of our Services, we act as the "data controller". To the extent EU data protection law applies to our processing of personal data about of users of your website, web or mobile applications ("End Users") we serve as the "data processor".

We use your information in order to:

Provide the Services to you:
To do this we also use your information to: Provide you with technical support and assistance in the development of the modules in your Application; ensure that the Services function well and communicate with you about the Services by email, forums, notifications within the Services (transactional messages). For example we will contact you to notify you of any issues with the Services or any suspicious activity in your account or use what we learn about your End Users' interactions with your application and with advertising to provide you with information you can use to improve your application. The legal basis for these uses in the performance of the contract with you.

In some cases, your use of information provided to you by us may require the End User's consent. It is your responsibility to disclose clearly, and obtain consent as required by applicable data protection law.

Improve the Services:
We use your information, but not your End Users' information, for analytics and measurement to understand how our Services are used in order to make improvements to our services or develop new components to the Services through understanding how you, but not your End Users use and interact with them, including how you interact with applications, advertising, products, and services that are made available, linked to, or offered through the Services.

The legal basis for these uses is our legitimate interest in the improvement and optimization of our service offerings and in ensuring the security of our services and we apply appropriate safeguard to protect your information (see Section 6 below).

Comply with Legal Requirements and Protect Our Rights:
When needed, we use your information to enforce this Privacy Policy, the Terms of Use (https://www.digitalflare.io/terms.html) and any other terms that you have agreed to, including to protect the rights, property, or safety of DigitalFlare, its users, or any other person, or the copyright-protected content of the Services as well as to comply with our legal obligations.

The legal basis for these uses is our legitimate uses in the performance of our contractual obligations; protection of our legal rights, compliance with legal obligations and protection of the rights of users and other individuals.

Tell you about our new products or services:
If you agree, we will contact you by email to inform you of new products and Services that might be of interest to you. You can opt out of such email communications at any time by clicking the "unsubscribe" link at the bottom of each email or by contacting us at [email protected]

DigitalFlare representatives may send you connection requests or messages on social media. You may decline such requests or remove the connection at any time.

We share information collected about your End Users with service providers that assist use with the provision of our Services, as well as in connection with a business transaction or as necessary to comply with our legal obligations.

With Service Providers:
We share your information and that of your End Users with service providers to perform functions and process your data and to help provide our Services, consistent with this Privacy Policy. For example, we work with service providers to host the DigitalFlare Services. We also work with analytics providers, including Google Analytics (see above) to help us understand your use of our Services. Other service providers include Website hosting, Marketing Automation, CRM, Cloud File Storage, Accounting software and communication software. The legal basis for this sharing of your information is our legitimate interest in providing our Services efficiently.

Any information DigitalFlare provides to third party services is protected by an appropriate agreement ensuring that it is only used for the purposes for which it was provided. When DigitalFlare receives personal information under the Privacy Shield, as explained below, and then transfers it to third party services, we are liable for any processing of personal information by such third parties that is inconsistent with the Privacy Shield Principles unless we are not responsible for the event giving rise to any alleged damage. In addition, we apply appropriate safeguard to protect your information (see Section 6 below)

With our affiliates and In connection with a business reorganization:
We share your information and that of your End Users with our parent company, subsidiaries, joint ventures, or other companies under common control with DigitalFlare in the ordinary operation of our business. In addition, we would share your information, or that of your End Users, if we are involved in a merger, acquisition, consolidation, change of control or sale of all or a portion of our assets or if we undergo bankruptcy or liquidation. The legal basis for this sharing is our legitimate interest in carrying out our business operations.

In order to comply with our legal obligations, protect our rights and those of others:
We share your information and that of your End Users, per your instructions, in order to prevent fraud or abuse to our services, to protect your rights, to comply with our legal obligations and to protect our rights. [each of these should be a click to the below]. The legal basis for this sharing is compliance with the law and our legitimate interest in the prevention of fraud, compliance with legal obligation and the protection of the rights of others.

Pursuant to your instructions:
When requested, we will share or facilitate the sharing of End User information with third parties pursuant to your instructions. We do not have any legal relationship with such parties. You are responsible for entering into separate contractual arrangements with such third parties binding them to comply with data protection obligations. These third party data processors are not sub-processors and we shall not bear any responsibility or liability for sharing information with such parties. The legal basis for this sharing is necessary for the performance of our contract with you.

Prevent fraud and abuse of the Services:
We will share information to prevent or detect fraud or to address technical issues and if we believe it is necessary to investigate, prevent, or take action regarding situations that involve abuse of the Services infrastructure or the Internet in general (such as voluminous spamming, denial of service attacks, or attempts to compromise the security of the website infrastructure or the Services generally).

Protect your rights:
We will share information in an emergency or to protect the safety of any person and if we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, fraud, or situations involving potential threats to the rights, property, or personal safety of any person.

Protect our rights and comply with our legal obligations:
We will share information if we are legally required to do so, such as in response to court orders or legal process (e.g., a court order or subpoena), or to establish, protect, or exercise our legal rights or to defend against legal claims or demands, or to comply with requirements of mandatory applicable law. We will also share information as necessary to enforce this Privacy Policy the Terms of Use (http://digitalflare.io/terms.html) and any other terms that you have agreed to, including to protect the rights, property, or safety of DigitalFlare, its users, or any other person, or the copyright-protected content of the Services.

We also process and share information in an aggregated, de-identified manner, where the information is shared as part of a statistical report and does not contain personal information.

Please see the section "Cookies and Other technologies" below for information about the technologies that we and third parties use to collect information and to learn about options in connection with these.

Sharing Information with Social Media Services:
If you have given permission in connection with using the third party services for the purpose of signing in, or on your preferences set with the third party service, some information about you can be shared with social media services and with others through third party services and may be published by them or may be shared by default. You understand and agree that a third party service's use of information collected from you (or as authorized by you) is governed by the third party service's privacy policies and your settings on the relevant service, and that our use of such information is governed by this Privacy Policy and your DigitalFlare account settings.

The Services may contain links to third party sites that are not owned or controlled by DigitalFlare. We have no control over the content, privacy policies, or practices of any third party site. You are subject to the policies of those third party sites where applicable. We encourage you to ask questions before you disclose your Personal Information.

We take reasonable precautions to protect your personal information. For example, all personal information collected by us is transferred over https and all personal information stored by us or for us is kept on a server in a secure environment. Only employees, our partners and any sub-contractors who need the information to perform a specific service are granted access to the information. All of our employees that have access to personal information are bound by confidentiality obligations. Please keep in mind that the Internet is not a 100% secure medium for communication, and we cannot guarantee that your personal information will always remain private when using the Services.

If you are a user of the Services: The Services are not directed to children under the age of 16. We do not knowingly collect Personal Information from children under 16. If you are under 16, please do not use the Services and do not provide any personal information to us. If you become aware that a child under 16 is a user of the Services and has provided us with personal information without parental consent, please contact us at [email protected].

If you are an End User:
We have no direct relationship with our users' customers or end users whose personal data we process. Our users are responsible for acquiring any parental consent necessary from End Users who are under 16 as may be required by applicable law. If you are an End User who is under 16 and wish your information to be deleted or to have any other action be taken with respect to your information, please contact our user (the "data controller) as set forth in Section 8 of this notice. If you are a California resident under the age of 18 and you wish to remove publicly available content, please contact us at [email protected] with the subject line "California Eraser".

If you are a user or an End User or our services, and reside in the EU you are entitled by law as well as under the Privacy Shield principles (see below) to access, correct, amend, or delete personal information about you that we hold. A list of these rights is below.

If you are an End User:
We have no direct relationship with our user's customers or end users whose personal data we process. If you are an End User, and you would like to access, amend or delete your data or otherwise exercise your data subject rights under applicable EU data protection law, then you need to contact our user (the "data controller") directly and we will respond within a reasonable period of time to any such request by our user.

If you are a user of our services:
You may access your DigitalFlare account to access, correct or delete the information you provided to us, or information we hold about your End Users, and which is associated with your account. For instructions on accessing your information or otherwise for assistance with these rights please write us at [email protected].

In the event that we refuse a request under rights of access, we will provide the individual with a reason as to why. Individuals in the EU have the right to complain as outlined in Section 15 below.

A list of your rights is below:

Right of access The right to request a copy of the information that we hold about the individual.

Right of rectification The right to correct data that we hold about the individual that is inaccurate or incomplete.

Right to be forgotten in certain circumstances the individual can ask for the data we hold about him or her to be erased from our records.

Right to restriction of processing where certain conditions apply to have a right to restrict the processing.

Right of portability the right to have the data we hold about the individual transferred to another organization.

Right to object you have the right to object to certain types of processing such as direct marketing (to the extent applicable). We do not engage in any marketing to the End Users of the Services.

Right to object to automated processing, including profiling the right to not be subject to the legal effects of automated processing or profiling.

You may also have the right to make a GDPR complaint to the relevant Supervisory Authority. A list of Supervisory Authorities is available here. If you need further assistance regarding your rights, please contact us using the contact information provided below and we will consider your request in accordance with applicable law. In some cases our ability to uphold these rights for you may depend upon our obligations to process personal information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.

9. What can you do about how we use your information

Email communication:
Users may opt out of receiving promotional email communication from DigitalFlare by clicking the "unsubscribe" link provided with each email. We will continue to send you notifications necessary for the Services to this email address.

Cookies and trackers:
For information on how to opt out of some of the collection of information about you see below in the Section entitled: "Cookies and Other Technologies – What Can You Do About Them?"

Deleting your account:
You may request that we delete your account or delete information pertaining to your End Users by writing us at [email protected]. If you choose to delete your account, we will begin the process of deleting your account from our systems. We will retain your Personal Information until the earlier of (i) the information is no longer necessary to accomplish the purpose for which it was provided; or (ii) you delete your account as stated above. We will retain End User information under the end of the Services engagement with you or pursuant to a legally binding request for erasure.

10. How Long Do We Keep Your Information

We retain your information or that of the End User for longer periods for specific purposes to the extent that we are obliged to do so in accordance with applicable laws and regulations and/or as necessary to protect our legal rights or for certain business requirements. For example, when we process your payments, we will retain this data for longer periods of time as required for tax or accounting purposes. To read more about specific reasons we would retain some data for longer periods of time click here:

Security, fraud & abuse prevention:
i.e. to protect you, other people, and DigitalFlare from fraud, abuse, and unauthorized access.

Financial record-keeping:
When you make a payment to us we are often required to retain this information for long period of time for purposes of accounting, dispute resolution and compliance with tax, anti-money laundering, and other financial regulations

Complying with legal or regulatory requirements:
To meet any applicable law, regulation, legal process or enforceable governmental request, as required to enforce our terms of service, including investigation of potential violations.

Ensuring the continuity of our services:
For example, when you share information with other users, deleting it from your account will not eliminate copies maintained by the recipients

Direct communications with us:
If you have directly communicated with us , through a customer support channel, feedback form, or a bug report, we may retain reasonable records of those communications.

Even if you delete your account, keep in mind that the deletion by our third party providers may not be immediate and that the deleted information may persist in backup copies for a reasonable period of time. Also, information that had already been shared with third parties may not be deleted by them. For any privacy or data-protection-related questions, please write to [email protected].

11. Cross Border Transfer

DigitalFlare transfers, processes and stores information about you on servers located in a number of countries, including the United States. We also subcontract processing to, or share your information with, third parties located in countries other than your home country.

Transfers of Information from the EEA and Switzerland:

For EU and Swiss Individuals: Privacy Shield Notice for Personal Data Transfers to the United.

DigitalFlare Ltd. will conduct any transfers of personal information from the European Economic Area (EEA) or from Switzerland to the US in compliance with the EU–US Privacy Shield Framework and the Swiss–U.S. Privacy Shield Framework ("Privacy Shield") as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal information from European Union member countries and Switzerland transferred to the United States pursuant to Privacy Shield. DigitalFlare has certified to the Department of Commerce that we adhere to the Privacy Shield Principles with respect to such data. If there is any conflict between the policies in this Privacy Policy and data subject rights under the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/.

With respect to personal data received or transferred pursuant to Privacy Shield, DigitalFlare is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.

If we become subject to an FTC or court order based on non-compliance, DigitalFlare shall make public any relevant Privacy Shield-related sections of any compliance or assessment report submitted to the FTC, to the extent consistent with confidentiality requirements.

Pursuant to the Privacy Shield Frameworks, EU and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also may correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under Privacy Shield, should direct their query to [email protected]. If requested to remove data, we will respond within a reasonable timeframe.

We will provide an individual opt-out or opt-in choice before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to [email protected]

In certain situations, DigitalFlare may be required to disclose PII personal information in response to lawful requests by public authorities, including in order to meet national security or law enforcement requirements. For more information, please see Section 4 above headed "What do we do with the information collected?"

DigitalFlare's accountability for personal data that it receives in the United States under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, DigitalFlare remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless DigitalFlare proves that it is not responsible for the event giving rise to the damage.

In compliance with the Privacy Shield Principles, DigitalFlare commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union and Swiss individuals with Privacy Shield inquiries or complaints should first contact us at [email protected].

DigitalFlare has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. This service is provided free of charge to you.

If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction

Transfers of information not from the EEA

To the extent that personal information is transferred to the United States from countries other than countries within the European Economic Area and Switzerland, including personal information that is transferred from Canada, we employ similar safeguards such as selecting third party vendors carefully, ensuring personal information will be used and disclosed only as set out in this privacy policy and that it is protected by appropriate security safeguards.

However, in connection with these transfers of personal information, your personal information may be subject to privacy laws that may not provide the same protection as your country of residence. For example, government entities in such other countries may have certain rights to access your personal information. By using this Site or using our products or services that this privacy notice relates to you are consenting to this transfer of your personal information.

12. Cookies and Other Tecnhologies

12.1 What Are They For? Cookies are text information files that your web browser places on your computer, mobile phone, or other device when you visit a website. The cookie will help website providers recognize your device the next time you visit their website. [There are other similar technologies such as pixel tags (transparent graphic images placed on a web page or in an email, that indicate whether it had been viewed), web bugs (similar to pixel tags), and local storage objects (using mechanisms such as browser web storage (including HTML 5) and application data caches), which are used in desktop software or mobile devices.

There are also technologies such as Software Development Kits (SDKs) or Advanced Programming Interfaces (APIs) to facilitate the same types of processes we use cookies for, as described above.

12.2 What Do We Use Them For? We and our third party providers use both session cookies (that expire once you close your web browser) and persistent cookies (which stay on the device for a set period of time or until you delete them) in order to operate our services, and in order to optimize them through the performance of analytics.

Required These cookies are required for making use of the Services. These cookies include security cookies to authenticate users, prevent fraudulent use of login credentials, and protect user data from unauthorized parties as well as session cookies that remember your log-in session so you can move easily within the Services.

Functional These cookies record some of your activity on the Services as well as information about your device, such as what browser you are running, and what pages you access. This information helps us and our third party service providers diagnose server and software errors, and in cases of abuse, track and mitigate the abuse.

Analytics Our service providers, including Google Analytics, use cookies as part of their tools. These cookies allow our service providers and us to recognize and count the number of users of the Services, to see how they move around the Platform, and how they engage with different functions, including usage statistics, when they are using the Services. This helps us to improve the way our Services work, for example by making sure our users are finding what they need easily.

12.3 What Can You Do About Them? Most browsers accept cookies automatically, but can be configured not to accept them or to indicate when a cookie is being sent. Please note that without cookies, you may not be able to take full advantage of all of the features of the Services. You can opt out of the collection of your information through Google Analytics [link below].

General Most browsers accept cookies automatically, but can be configured not to accept them or to indicate when a cookie is being sent. Please note that without cookies, you may not be able to take full advantage of all of the features of the Services. Turning off the browser's cookies will prevent web beacons from tracking your specific activity. The web beacon may still record an anonymous visit from your IP address, but unique information will not be recorded. If you do not want to receive tracking pixels, you will need to disable HTML images in your email client, and that may affect your ability to view images in other emails that you receive. You can find more information about cookies at http://www.allaboutcookies.org/.

Choice with respect to Google Analytics:
You can control the information provided to Google and opt out of certain ad provided by Google by using of the of the methods set forth http://www.google.com/policies/privacy/partners/ or downloading the Google Analytics opt-out browser add-on for Google Analytics which can be found here [https://tools.google.com/dlpage/gaoptout/]

13. Browser Do Not Track

The Services do not support Do Not Track at this time. Do Not Track (DNT) is a privacy preference you can set in your web browser to indicate that you do not want certain information about your webpage visits collected across websites when you have not interacted with that service on the page. For all the details, including how to turn on Do Not Track, visit donottrack.us.

14. Changed to Privacy Policy

Your continued use of the Services after the changes have been made will constitute your acceptance of the changes. Please therefore make sure you read any such notice carefully. If you do not wish to continue using the Services under the new version of the Privacy Policy, please cease using the Services.

15. Complaints and Dispute Resolution

In compliance with the Privacy Shield Principles, DigitalFlare commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union and Swiss individuals with Privacy Shield inquiries or complaints should first contact us at [email protected].

DigitalFlare has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. This service is provided free of charge to you.

If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction

16. Questions or Comments

We welcome questions and comments about this Privacy Policy. Questions or comments should be directed to [email protected]

DigitalFlare Ltd.
114 Igal Alon
Tel-Aviv, Israel